We’ve all seen the ads. “Need cash fast?” a speaker asks. “Have bad credit? You can get up to $1,000 within 24 hours.” The ad then directs you to a sketchy-sounding website, like 44cash.com, or a slightly-less-sketchy-sounding business, like PLS Loan Store. Most of us roll our eyes or go grab another beer when these commercials air. But 12 million people a year turn to payday lenders, who disguise the real cost of these loans. Borrowers often become saddled with unaffordable loans that have sky-high interest rates.

For years, states have tried to crack down on these deceptive business practices. Now, the Consumer Financial Protection Bureau (CFPB) is giving it a shot. On Monday, the New York Times reported that the CFPB will soon issue the first draft of new regulations on the $46 billion payday-lending industry. The rules are being designed to ensure borrowers have a better understanding of the real cost of payday loans and to promote a transparent and fair short-term lending market.

On the surface, payday loans sound like a good idea to many cash-strapped Americans. They offer a short-term loan—generally two weeks in length—for a fixed fee, with payment generally due on the borrower’s next payday. The average borrower takes out a $375 two-week loan with a fee of $55, according to the Pew Charitable Trust’s Safe Small-Dollar Loans Research Project which has put out multiplereports on payday lenders over the past few years. But payday lenders confuse borrowers in a couple of ways.

First, borrowers are rarely able to pay back their loans in two weeks. So they “roll over” the payday loan by paying just the $55 fee. Now, they don’t owe the $375 principal for another two weeks, but they’re hit with another $55 fee. That two-week, $375 loan with a $55 fee just effectively became a four-week, $375 loan with a $110 fee. If, after another two weeks, they still can’t repay the principal, then they will roll it over again for yet another $55 fee. You can see how quickly this can spiral out of control. What started as a two-week loan can last for months at a time—and the fees borrowers incur along the way end up dwarfing the principle. Pew found that the average borrower paid $520 in fees for the $375 loan, which was rolled over an average of eight times. In fact, using data from Oklahoma, Pew found that “more borrowers use at least 17 loans in a year than just one.”

Second, borrowers are often confused about the cost of the loan. The $55 fee—payday lenders often advertise a fee of $15 per $100 borrowed—sounds like a reasonable price for a quick infusion of cash, especially compared to a credit card with a 24-percent annual percentage rate (APR). But that’s actually an extremely high price. Consider the standard two-week, $375 loan with a $55 fee. If you were to roll that loan over for an entire year, you would pay $1,430 in fees ($55 times 26). That’s 3.81 times the original $375 loan—an APR of 381 percent.

Many borrowers, who badly need money to hold them over until their next paycheck, don’t think about when they’ll actually be able to pull it back or how many fees they’ll accumulate. “A lot of people who are taking out the loan focus on the idea that the payday loan is short-term or that it has a fixed $55 fee on average,” said Nick Bourke, the director of the Pew research project. “And they make their choice based on that.”

Lenders advertise the loans as a short-term fix—but their business model actually depends on borrowers accruing fees. That was the conclusion of a 2009 study by the Federal Reserve of Kansas City. Other research has backed up the study’s findings. “They don’t achieve profitability unless their average customer is in debt for months, not weeks,” said Bourke. That’s because payday lending is an inefficient business. Most lenders serve only 500 unique customers a year, Pew found. But they have high overhead costs like renting store space, maintaining working computers, and payroll. That means lenders have to make a significant profit on each borrower.

It’s also why banks and other large companies can offer short-term loans at better prices. Some banks are offering a product called a “deposit advance loan” which is nearly identical to a payday loan. But the fees on those loans are far smaller than traditional payday loans—around $7.50-$10 per $100 loan per two-week borrowing period compared with $15 per $100 loan per two-week period. Yet short-term borrowers are often unaware of these alternatives. In the end, they often opt for payday loans, which are much better advertised.

The CFPB can learn a lot about how to (and how not to) formulate its upcoming regulations from state efforts to crack down on payday lenders. Fourteen states and the District of Columbia have implemented restrictive rules, like setting an interest-rate cap at 36 percent APR, that have shutdown the payday-loan business almost entirely. Another eight states have created hybrid systems that impose some regulations on payday lenders, like requiring longer repayment periods or lower fees, but have not put them out of business. The remaining 28 states have few, if any, restrictions on payday lending:

The CFPB doesn’t have the power to set an interest rate cap nationally, so it won’t be able to stop payday lending altogether. But that probably shouldn’t be the Bureau’s goal anyways. For one, eliminating payday lending could have unintended consequences, such as by driving the lending into other unregulated markets. In some states, that seems to have already happened, with payday lenders registering as car title lenders, offering the same loans under a different name. Whether it would happen on a large scale is less clear. In states that have effectively outlawed payday lending, 95 percent of borrowers said they do not use payday loans elsewhere, whether from online payday lenders or other borrowers. “Part of the reason for that is people who get payday loans [are] pretty much mainstream consumers,” Bourke said. “They have a checking account. They have income, which is usually from employment. They’re attracted to the idea of doing business with a licensed lender in their community. And if the stores in the community go away, they’re not very disposed towards doing business with unlicensed lenders or some kind of loan shark.”

In addition, borrowers value payday lending. In Pew’s survey, 56 percent of borrowers said that the loan relieved stress compared to just 31 percent who said it was a source of stress. Forty-eight percent said payday loans helped borrowers, with 41 percent saying they hurt them. In other words, the short-term, high-cost lending market has value. But borrowers also feel that lenders take advantage of them and the vast majority want more regulation.

So what should that regulation look like? Bourke points to Colorado as an example. Lawmakers there capped the annual interest payment at 45 percent while allowing strict origination and maintenance fees. Even more importantly, Colorado requires lenders to allow borrowers to repay the loans over at least six months, with payments over time slowly reducing the principal. These reforms have been a major success. Average APR rates in Colorado fell from 319 percent to 129 percent and borrowers spent $41.9 million less in 2012 than in 2009, before the changes. That’s a 44 percent drop in payments. At the same time, the number of loans per borrower dropped by 71 percent, from 7.8 to 2.3.

The Colorado law did reduce the number of licensed locations by 53 percent, from 505 to 238. Yet, the number of individual consumers fell just 15 percent. Overall, that leads to an 81 percent increase in borrowers per store, making the industry far more efficient and allowing payday lenders to earn a profit even with lower interest rates and a longer repayment period.

Bourke proposes that the CFPB emulate Colorado’s law by requiring the lenders to allow borrowers to repay the loans over a longer period. But he also thinks the Bureau could improve upon the law by capping payments at 5 percent of borrower’s pretax income, known as an ability-to-repay standard. For example, a monthly payment should not exceed 5 percent of monthly, pretax income. Lenders should also be required to clearly disclose the terms of the loan, including the periodic payment due, the total cost of the loan (all fee and interest payments plus principal), and the effective APR.

The CFPB hasn’t announced the rules yet. But the Times report indicated that the Bureau is considering an ability-to-repay standard. The CFPB may also include car title lenders in the regulation with the hope of reducing payday lenders’ ability to circumvent the rules. However, instead of requiring longer payment periods, the agency may instead limit the number of times a lender could roll over a borrower’s loan. In other words, borrowers may only be able to roll over the loan three or four times a year, preventing them from repeatedly paying the fee.

If the Bureau opts for that rule, it could limit the effectiveness of the law. “That kind of tries to tackle a problem of repeat borrowing and long-term borrowing but that’s a symptom,” Bourke said. “That’s not really the core disease. The core disease is unaffordable payments.” In addition, it could prevent a transparent market from emerging, as payday lenders continue to take advantage of borrowers’ ignorance over these loans. “The market will remain in this mire,” Burke added, “where it’s dominated by a deceptive balloon payment product that makes it difficult for consumers to make good choices but also makes it difficult for better types of lenders to compete with the more fair and transparent product.” Ultimately, that’s in the CFPB’s hands.

Protesters from the anti-poverty advocacy group ACORN rally outside a new Cash Money payday loan store on Kingsway at Griffiths. The group says the City of Burnaby should limit the number of such outlets and their proximity to each other.

— image credit: MARIO BARTEL/NEWSLEADER

Their chants expended, a small group of protestors from the anti-poverty advocacy group ACORN tucked their placards under their arms on Tuesday and strolled from in front of a Cash Money payday loan outlet at Kingsway and Griffiths to a Money Mart 200 metres east.

Which was just the reason for their ire.

Monica McGovern, the chairperson of ACORN’s Burnaby chapter, said there’s too many short-term lending establishments too close to each other in the city. That makes it too easy for low-income people who may not use conventional banks to access expensive loans.

Eventually they’re snowed under by their obligations to the lenders, further miring them in poverty, said McGovern.

“This is the poor they’re exploiting,” said McGovern. “They set people up for failure.”

The Cash Money outlet where ACORN members protested opened on Jan. 14.

But with another pay day lender close by already, McGovern said it’s time the City of Burnaby start limiting the licenses for such establishments.

“We’re concerned because these stores keep on popping up,” said McGovern.

Their proximity to each other allows clients from skirting provincial regulations that prevent a pay day lender from advancing money if the client already has an outstanding loan to that lender; the customer just has to walk down the street to get the money, along with the increased debt.

But fighting that regulatory battle, along with high interest rates such lenders charge – up to 23 per cent – is ongoing, said McGovern.

Meanwhile, municipalities like Burnaby can take steps to restrict the access impoverished people have to payday lenders.

“We urge city council to address this issue and limit the proliferation of these businesses,” said McGovern who pointed out nothing has happened at the civic level since ACORN made a presentation to council last February.

The issue was referred to the Community Development Committee for further study.

In April the City of Surrey proposed an amendment to its bylaws to create at least 400 metres separation between payday loan stores.

EVELETH — The Iron Range Resources & Rehabilitation Board’s Loan Guaranty program for local businesses has received a $350,000 infusion from the agency’s Business Development Project Fund.

The program, which is an initiative of outgoing Commissioner Tony Sertich to provide more financial help for existing Iron Range small businesses, provides loan guarantees of up to $75,000 under certain guidelines.

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Strict new price caps will come into force in the U.K.’s payday loans market in January, sector regulator the Financial Conduct Authority (FCA) has confirmed, affecting any U.K. businesses that offer this type of short-term consumer credit.

The FCA said today that from January 2, 2015 it will be imposing an initial cost cap of 0.8 per cent per day for all high-cost short-term credit loans, which means interest and fees must not exceed 0.8 per cent per day of the amount borrowed.

It will also be applying a total cost cap of 100 per cent on a loan, meaning a borrower must never pay back more than 100 per cent of the amount they borrowed in order to protect them from escalating debts. Fixed default fees are also capped at £15 for borrowers who do not make loan repayments on time. And interest on unpaid balances and default charges must not exceed the initial rate.

The result of the regulatory caps will be a far smaller payday loans market, and one which can’t generate huge profits at the expense of the most vulnerable borrowers. Last year one payday loans company, Wonga, listed its representative annual interest rate at 5,853 per cent.

In the first five months since the FCA has been regulating the sector it said the number of loans and the amount borrowed has dropped by 35 per cent. Going forward, it is estimating the new price caps will mean seven per cent of current borrowers may no longer have access to payday loans — some 70,000 people.

“These are people who are likely to have been in a worse situation if they had been granted a loan. So the price cap protects them,” it notes.

Caps on the payday loans market have been expected since 2013, when the duty to cap the cost of credit was formally established through the Financial Services (Banking Reform) Act 2013. The FCA spent this summer consulting on its proposed caps and has today confirmed the levels it was consulting on.

“I am confident that the new rules strike the right balance for firms and consumers. If the price cap was any lower, then we risk not having a viable market, any higher and there would not be adequate protection for borrowers,” said Martin Wheatley, the FCA’s chief executive officer, in a statement.

“For people who struggle to repay, we believe the new rules will put an end to spiralling payday debts. For most of the borrowers who do pay back their loans on time, the cap on fees and charges represents substantial protections.”

The FCA notes that from January 2, no borrower will ever pay back more than twice what they borrowed, while someone taking out a loan for 30 days and repaying on time will not pay more than £24 in fees and charges per £100 borrowed.

Wonga still looks to be charging higher rates of interest and fees than the impending price caps will allow. A loan fee calculator on its website states that a £100 loan taken out for 30 days will incur interest and fees of £37.15. But from January 2 the same loan will have its interest and fees capped at £24.

Last month Wonga was forced by the FCA to write off the debts of some 330,000 customers, and waive the fees and charges of a further 45,000 — taking a write down of around £220 million — after admitting its affordability checks had been inadequate.

It has put in place interim measures to test affordability, and is in the process of rolling out a new permanent lending decision platform that reflects the new affordability criteria. But the company — which for years touted the speed and efficiency of its technology platform in making lending decisions – will clearly see its business shrink further when the new price caps come into place.

Oct 20 (Reuters) – Sears Holdings Corp said it would raise as much as $625 million through an unsecured loan and equity warrants, its third fundraising in a month, as it seeks to ease suppliers’ concerns about its finances going into the critical holiday season.

Shares of the retailer jumped 21.4 percent to $34.5 on the news.

Sears said Chief Executive Officer Eddie Lampert and his hedge fund, ESL Investments Inc, would purchase roughly half of the offering, in which the right to buy unsecured senior notes and warrants will be issued to existing shareholders.

If the offering is fully subscribed, it could bring the retailer’s total fundraising this year to $2.07 billion, double the target set in March. The additional funds “will provide confidence to our vendors and other constituents,” Chief Financial Officer Rob Schriesheim wrote in a blog post.

The move comes after some insurers who offer protection to suppliers against the risk of nonpayment had cancelled or scaled back their coverage of Sears in recent weeks due to concerns over the company’s finances, people familiar with the matter told Reuters.

Analysts and suppliers said the latest funding would ease, but not eliminate, worries about Sears as a credit risk.

“It helps for this year. They will still have to inject liquidity for the next year,” given how quickly they are burning through cash, said Fitch Ratings analyst Monica Aggarwal. “There is a need for cash inflow to keep the operations going.”

Sears also announced on Monday that it would lease out seven stores to British discount fashion chain Primark for an undisclosed amount. It has been seeking to clinch such deals to earn income on underperforming space in its roughly 2,000 U.S. stores.

The fundraising marks the third time Sears has turned to Lampert for money in recent weeks. In September ESL anchored a $400 million loan, and earlier this month the fund agreed to buy $168 million out of a rights offering in Sears’ Canadian unit aimed at raising up to $380 million.

Sears said the clients of its second largest shareholder, Fairholme Capital Management, would subscribe to the latest offering. Fairholme owns 24 percent of Sears while ESL and Lampert together own 48.5 percent, Thomson Reuters data show.

Each subscription right will give the holder the right to buy one unit, comprising a senior unsecured note due 2019 and paying 8 percent interest as well as warrants to purchase common shares at a strike price of $28.41. The number of warrants will be set after the principal of the notes is fixed, Sears said.

The rally in Sears’ stock was in part due to the fact that Lampert had agreed to put in money on unsecured terms, analysts said. Last month’s $400 million loan had spooked some investors and suppliers because it was secured against 25 stores.

“I think this financing shows more of a longer-term support, and its unsecured so it’s certainly a stronger statement than the real estate financing,” said Moody’s analyst Scott Tuhy.

Tuhy said the latest financing would not ease concerns over the company’s operations.

Sears has lost almost $1 billion in the last two quarters as it struggles to cut costs to keep pace with dwindling sales.

During the housing bust, many homeowners were cut off from a popular source of funds: their homes.

But as home prices recover, more people have been able to tap their home’s equity to pay for renovations, consolidate debts or help pay for other big ticket items.

Home equity lines of credit were up 27% during the year ended June 30, according to financial services company Experian and consulting firm Oliver Wyman. And more people are expected to follow suit.

But does that mean a home equity loan (HEL) or home equity line of credit (HELOC) is right for you?Here are five things you need to consider.

1. Rates

In recent years, mortgage rates have hovered near historic lows — with nearly 9 million borrowers getting 30-year fixed mortgages at or below 4%, according to CoreLogic.

Now rates are expected to rise.

“We may be in for a more volatile period,” said Keith Gumbinger, of HSH.com, a mortgage information firm. Coming to an end next month are several of the Federal Reserve’s efforts to keep rates low under its quantitative easing monetary policy, he noted.

So if you are one of the borrowers who locked in an ultra-low rate in the past few years, a home equity loan or HELOC could save you more money than refinancing the entire mortgage through a cash-out refinance.

You can expect to pay inspection and attorney review fees, for example, and you will have to get a new title search and insurance, which can typically cost $1,000 or more, depending on the size of your mortgage. In total, all of those upfront costs of refinancing can put you back two to three grand depending on the size of your loan.

Meanwhile, some lenders issue home equity loans or lines of credit with no upfront costs; borrowers pay for their application, appraisal and other fees by paying a higher interest rate.

3. Time

When you take out a home equity loan or HELOC, you keep making your payments on the same payment schedule.

Soeven if you’ve paid 30 months on a 30-year loan and then refinance, when you make your first payment on the new loan it will be like starting at day one of the 30-year term.

However, if you opt to roll the 30-year loan into a 15-year one, that would then reduce the number of payments you make but increase the amount of your payments each month.

4. What the loan or line of credit is for

The best reason to take out a home equity loan is when it has some positive impact on your finances. Using it to pay for a renovation that adds value to your property, for example, or to pay for an advanced degree that can increase your earning power.

Of course, there are times when borrowing against your home doesn’t make sense.

It can be foolish to tap your home’s equity for nonessential spending, for example. Using home equity to buy a Mercedes, pay for a luxury vacation or make some other discretionary purchase can be a foolish move. The money will be gone and you will be paying off the debt for years to come.

Draining your home of equity can also put you on the road to foreclosure. Run into unexpected expenses and there’s one less source of funds to tap.

5.Tax benefits

Just like first mortgages, certain home equity loans and HELOCs are eligible for the home mortgage interest deduction. Borrowers can deduct up to $100,000 ofinterest paid on a mortgage’s principal.

Toxic finance: Reckless payday lender Wonga wipes mountain of debt

Thousands of customers who took loans with controversial pay day lender Wonga are to have their debts written off, in an action expected to cost the ‘legal loan shark’ more than 200 million pounds.

The company will wipe the debts of 330,000 customers who are trapped in arrears of 30 days or more, while a further 45,000 customers will get to repay their loans exempt from interest.

The move is a “consequence” of Wonga’s discussions with the Financial Conduct Authority (FCA), who said the firm “was not taking adequate steps to assess customers’ ability to meet repayments in a sustainable manner.”

The FCA also said that Wonga did not do enough to vet customers and their ability to pay back the interest incurred on loans, which can be higher than 5,000 percent.

As a result, a large number of Wonga customers were forced to admit they were unable to pay the company back after taking out a short-term loan.

“We are determined to drive up standards in the consumer credit market and it is disappointing that some firms still have a way to go to meet our expectations,” said the FCA’s Director of Supervision Clive Anderson.

Last month, the payday lender recorded a profit loss of 53 percent – one of the largest slumps in its operating history.

The lender revealed its pre-tax profit in 2013 was 39.7 million pounds, down from 84.5 million the previous year.

Wonga said the fall was due to “remediation costs” – money that it had to pay back to its customers – including 2.6 million pounds it had to pay out to more than 45,000 customers after it delivered debt collection letters from non-existent law firms.

However, Wonga did record a 15 percent rise in the number of loans issued between 2012 and 2013, worth 4.6 million pounds.

Wonga’s Chairman Andy Haste told British media there was a “real and urgent” need for change.

He also told the BBC it expected to be “smaller” and “less profitable” following increased FCA regulations, which include more stringent background credit checks.

“Our regulator is determined to improve standards in consumer credit and I share that determination,” he said.

“There is much to do in order to make Wonga a sustainable and accepted business, and today’s announcement is a significant step forward in that process.

Labour MP John Mann called for Wonga to be brought before Parliament’s Treasury Select Committee to “explain how they lent so much money to people it knew could never afford to repay it.”

“Sadly, it comes as no surprise to learn that Wonga knowingly lent money to people who will never be able to afford to repay a loan and it is morally right that they have been forced to write off these loans,” he added.

This is not the first time Wonga has come under heavy criticism for its practices.

Since July, the firm has not been allowed to produce advertisements designed to attract young people, such as its campaign that used puppets, screened during children’s television programming – an attempt to soften the brand, critics allege.

In 2012, Wonga was also forced to apologize to Labour MP Stella Creasy after she received personal abuse via Twitter, calling her “nuts,” “pathetic” and “a raving self-publicist.”

The MP has long been outspoken on payday loan companies, and has lobbied the government to set a cap on the amount customers can be charged for small, short term loans.

While the MP welcomed the fall in Wonga’s profits, she said the rise in the number of loans being issued should be a cause of concern.

“The fact that they are reporting a 15 percent increase in customers for this toxic form of finance reflects that there are still millions of people for whom there is too much month at the end of their money,” she told the Financial Times.

Under new rules issued by the FCA, payday lenders will not be able to reclaim debts directly from customers’ bank accounts, while a cap of 0.8 percent interest per day has been proposed for short term loans.

According to the UK’s Public Accounts Committee, around 2 million people in the UK used payday loans, while the Office of Fair Trading believes around 1.8 billion pounds is loaned in high cost plans each year.

A YouGov survey of children aged 13 to 17 found almost three-quarters (72%) had seen or heard an advert for payday loans in the past seven days.

One-third of children found payday loan adverts fun, tempting or exciting, and this group were significantly more likely to say they would consider using a payday loan in the future.

Meanwhile, one-third of parents believed payday lenders’ adverts deliberately target children with more than one-quarter thinking the companies put pressure on children to pester their parents to borrow money.

It follows research by Ofcom last December which showed the number of payday loan adverts on TV had risen by more than 20 times over the past four years with more than half broadcast between 9.30am and 5pm.

The Children’s Society, through its Debt Trap campaign, is calling for restrictions on loan advertising to join those already in place to protect children from adverts for gambling, alcohol, tobacco and junk food.

In particular, the charity is urging the Government to amend the Consumer Rights Bill to ban payday loan advertisements on TV and radio before the 9pm watershed.

Matthew Reed, of The Children’s Society, said: “We see the devastating impact of debt on children’s lives.

“It has become a battle for families to pay bills, the mortgage or rent, and find money for food or other basics.

“One setback or a simple mistake can lead to a spiral of debt.

“Children are exposed to a barrage of payday loan adverts which put even more pressure on families struggling to make ends meet and provide the basics.”

To Avoid Late Fees

At some point in life, you will need to borrow money for unexpected expenses, and maybe you will need more money than what you can raise from borrowing from friends or family member. When you obtain a payday loan to pay for an emergency such as paying mortgage loan and utilities you will need to repay your loan on the due date with your next paycheck. However, when your next paycheck is no longer an option, it is important that you know how to pay off payday loans to avoid late fees, wage garnishment or lawsuit.

Pay off Payday Loans

Here are some helpful tips to pay off payday loans:

1. Talk to the Lenders

When you cannot repay your loan back on the due date, it is best that you talk to the lenders to discuss available repayment options and reach an agreement that benefit both parties.

Take note, lenders often times will provide you with repayment options like rollover plan and installment plan. They do not discuss these options to clients when they apply for a loan, so you need to ask the lenders about repayment options available to you.

Rollover is when you are allowed to extend the original due date to another date for an additional fee of course. Installment plan, on the other hand, allows you to repay your loan on an installment basis. Usually lenders stop charging loan interest for installment plan, as the purpose of the plan is to pay off payday loans completely. However, the number of installment payment depends on the lender.

2. Pick The Right Repayment Plan

When choosing the repayment option, make sure you pick a payment plan that you can follow and achievable.

3. Stop Buying Nonessential Stuff

You can pay off payday loans when you stop buying unimportant items before your due date. When you stop buying nonessential stuff and just start saving money for a payday loan payment then you can pay off all your debts fast.

Furthermore, the total payday loan debt handled by the charity increased from £51m to £72m year-on-year.

In a bid to curtail the payday loans sector, the FCA has proposed capping the amount lenders can charge at 100 per cent of the value of the loan. The new rules are due to come into force in January 2015.

In its response to the FCA consultation, published alongside today’s findings, StepChange urges the regulator to consider implementing a stricter cap.

It says: “There is a case for a tougher total cost cap than 100 per cent of the value of the loan, especially in relation to higher value loans.

“The Competition and Markets Authority found that the average initial payday loan taken out is £260, while the average StepChange Debt Charity client with payday loan debt has an income (net) of £1,305.

“This means that someone with just one payday loan debt which reaches the 100 per cent cap would end up owing a substantial part of their income and could easily lead to further borrowing and deeper financial difficulty.”

StepChange chief executive Mike O’Connor says: “High-cost short-term credit is rarely the answer to financial difficulties. While, the FCA’s proposed price cap is a crucial step forward, there is still much work to be done to ensure that payday loans can no longer plunge people into a cycle of unsustainable borrowing and entrenched financial hardship.

“Consumers will continue to need access to short-term credit and FCA action should also stimulate the reform of this market. This needs to include problems in the adjacent markets including overdrafts, logbook loans and home credit where consumers also suffer detriment.”